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{{#Wiki_filter:Comment Resolution Document Summary of Comments for Interim SA-104, Reviewing the Common Performance Indicator Technical Quality of Licensing Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC letter 20-004, date January 7, 2020 Comment Source   Location                     Comment                   Accepted               Remarks No.
{{#Wiki_filter:Comment Resolution Document Summary of Comments for Interim SA-104, Reviewing the Common Performance Indicator Technical Quality of Licensing Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC letter 20-004, date January 7, 2020 Comment No.
1      New       V. A. 3   Editorial Comments: Should procedures     No        This procedure applies to the UR Jersey                apply say procedures do not apply?                 and LLRW programs. The UR and LLRW procedure points back to UR and LLRW program both have their       No        this procedure for the general own SA procedures too. Should 3 and 4                 evaluation of licensing actions be combined in one paragraph to include               (e.g., thorough, complete, etc.)
Source Location Comment Accepted Remarks 1
all 3 of the non-common indicators?
New Jersey V. A. 3 Editorial Comments: Should procedures apply say procedures do not apply?
UR and LLRW program both have their own SA procedures too. Should 3 and 4 be combined in one paragraph to include all 3 of the non-common indicators?
No No This procedure applies to the UR and LLRW programs. The UR and LLRW procedure points back to this procedure for the general evaluation of licensing actions (e.g., thorough, complete, etc.)
This procedure does not apply to the evaluation of the licensing actions for SSDR.
This procedure does not apply to the evaluation of the licensing actions for SSDR.
2       New       V.B.2.h   Legally binding conditions or license       Yes      Language was added. Yes, Jersey                conditions Should this be requirements               license conditions are legally such as license conditions? Arent license           binding.
2 New Jersey V.B.2.h Legally binding conditions or license conditions Should this be requirements such as license conditions? Arent license conditions legally binding?
conditions legally binding?
Yes Language was added. Yes, license conditions are legally binding.
3       New       General   Is this text to ensure that they (license  No Action Submitting license conditions, Jersey                conditions) have been sent to the NRC for             other than those that point back to a compatibility review required or a                 a Programs regulation or are suggestion? I dont think this is a                   standard license conditions (e.g., in requirement for all license conditions.                NUREG-1556, Vol. 20), are required to be submitted to the NRC for review.
3 New Jersey General Is this text to ensure that they (license conditions) have been sent to the NRC for a compatibility review required or a suggestion? I dont think this is a requirement for all license conditions.
4       New       V.C.1     Editorial Comment Replace NRC or           Yes Jersey                Agreement State radiation control program for Program
No Action Submitting license conditions, other than those that point back to a Programs regulation or are standard license conditions (e.g., in NUREG-1556, Vol. 20), are required to be submitted to the NRC for review.
4 New Jersey V.C.1 Editorial Comment Replace NRC or Agreement State radiation control program for Program Yes


5   New       V.D.14 Provide clarification for: Implementation of No Action During IMPEP reviews we will Jersey          licensing initiatives. In particular, the               evaluate and mention in the report reviewer should identify these initiatives for           if a Program has other licensing initiatives, such as, a general a performance-based review (i.e.,
5 New Jersey V.D.14 Provide clarification for: Implementation of licensing initiatives. In particular, the reviewer should identify these initiatives for a performance-based review (i.e.,
licensing program or other radiography certification, general licensing             licensing programs.
radiography certification, general licensing programs, etc.).
programs, etc.).
No Action During IMPEP reviews we will evaluate and mention in the report if a Program has other licensing initiatives, such as, a general licensing program or other licensing programs.
6   Iowa     V.F.3 In Section V, Lettered Paragraph F,           Yes      SA-104 was updated to reflect Numbered Paragraph 3 states, "Section                   more general language for the II.A.3 of NMSS procedure SA-100 contains                 development of recommendations in SA-100. Most of the appendices criteria regarding the development of were removed from the SA recommendations by the IMPEP team." I                   procedures, including the appendix question that statement as Appendix D of                on development of SA-100 is titled "Criteria and Examples of               recommendations, and are Recommendations" and I don't see a                       available in the state Section II.A.3 in SA-100 anywhere?                       communication portal website at https://scp.nrc.gov/impeptools.html.
6 Iowa V.F.3 In Section V, Lettered Paragraph F, Numbered Paragraph 3 states, "Section II.A.3 of NMSS procedure SA-100 contains criteria regarding the development of recommendations by the IMPEP team." I question that statement as Appendix D of SA-100 is titled "Criteria and Examples of Recommendations" and I don't see a Section II.A.3 in SA-100 anywhere?
ADAMS ACCESSION NUMBERS     PACKAGE: ML20183A152                 COMMENT RESOLUTION DOCUMENT: ML20258A063}}
Yes SA-104 was updated to reflect more general language for the development of recommendations in SA-100. Most of the appendices were removed from the SA procedures, including the appendix on development of recommendations, and are available in the state communication portal website at https://scp.nrc.gov/impeptools.html.
ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20258A063}}

Latest revision as of 13:42, 30 November 2024

Comment Resolution Document SA-104
ML20258A063
Person / Time
Issue date: 01/07/2020
From:
Office of Nuclear Material Safety and Safeguards
To:
KATHY MODES/NMSS/MSST
Shared Package
ML20183A152 List:
References
Download: ML20258A063 (2)
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Text

Comment Resolution Document Summary of Comments for Interim SA-104, Reviewing the Common Performance Indicator Technical Quality of Licensing Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC letter 20-004, date January 7, 2020 Comment No.

Source Location Comment Accepted Remarks 1

New Jersey V. A. 3 Editorial Comments: Should procedures apply say procedures do not apply?

UR and LLRW program both have their own SA procedures too. Should 3 and 4 be combined in one paragraph to include all 3 of the non-common indicators?

No No This procedure applies to the UR and LLRW programs. The UR and LLRW procedure points back to this procedure for the general evaluation of licensing actions (e.g., thorough, complete, etc.)

This procedure does not apply to the evaluation of the licensing actions for SSDR.

2 New Jersey V.B.2.h Legally binding conditions or license conditions Should this be requirements such as license conditions? Arent license conditions legally binding?

Yes Language was added. Yes, license conditions are legally binding.

3 New Jersey General Is this text to ensure that they (license conditions) have been sent to the NRC for a compatibility review required or a suggestion? I dont think this is a requirement for all license conditions.

No Action Submitting license conditions, other than those that point back to a Programs regulation or are standard license conditions (e.g., in NUREG-1556, Vol. 20), are required to be submitted to the NRC for review.

4 New Jersey V.C.1 Editorial Comment Replace NRC or Agreement State radiation control program for Program Yes

5 New Jersey V.D.14 Provide clarification for: Implementation of licensing initiatives. In particular, the reviewer should identify these initiatives for a performance-based review (i.e.,

radiography certification, general licensing programs, etc.).

No Action During IMPEP reviews we will evaluate and mention in the report if a Program has other licensing initiatives, such as, a general licensing program or other licensing programs.

6 Iowa V.F.3 In Section V, Lettered Paragraph F, Numbered Paragraph 3 states, "Section II.A.3 of NMSS procedure SA-100 contains criteria regarding the development of recommendations by the IMPEP team." I question that statement as Appendix D of SA-100 is titled "Criteria and Examples of Recommendations" and I don't see a Section II.A.3 in SA-100 anywhere?

Yes SA-104 was updated to reflect more general language for the development of recommendations in SA-100. Most of the appendices were removed from the SA procedures, including the appendix on development of recommendations, and are available in the state communication portal website at https://scp.nrc.gov/impeptools.html.

ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20258A063

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